Judgment for defendant, 231 F.Supp. 393 (N.D. Ga. 1964). Appeal from the United States Court of the Northern District of Georgia

Subsequent history

None

Holding

Congress did not unconstitutionally exceed its powers under the Commerce Clause by enacting Title II of the 1964 Civil Rights Act, which prohibited racial discrimination in public accommodations. Northern District of Georgia affirmed.

Contents

Background

This important case represented an immediate challenge to the Civil Rights Act of 1964, the landmark piece of civil rights legislation which represented the first comprehensive act by Congress on civil rights and race relations since the Civil Rights Act of 1875. For much of the 100 years preceding 1964, race relations in the United States had been dominated by segregation, a system of racial separation which, while in name provided for "separate but equal" treatment of both white and black Americans, in truth perpetuated inferior accommodation, services, and treatment for black Americans.

The Case

The Heart of Atlanta Motel was a large, 216-room motel in racial discrimination in public places, largely based on Congress' control of interstate commerce—the motel refused to rent rooms to black patrons. The owner, Moreton Rolleston, filed suit in federal court, arguing that the requirements of the act exceeded the authority granted to Congress over interstate commerce. In addition, Rolleston maintained that the act violated his Fifth Amendment rights to choose customers and operate his business as he wished and resulted in unjust deprivation of his property without due process of law and just compensation. Finally, he contended that Congress had placed him in a position of involuntary servitude by forcing him to rent available rooms to blacks, thereby violating his Thirteenth Amendment rights.

In response, the United States countered that the restrictions requiring adequate accommodation for black Americans were unquestionably related to interstate travel, and that Congress, under the Constitution's Commerce Clause, certainly had the power to address such a matter in law. It further argued that the Fifth Amendment does not forbid reasonable regulation of interstate commerce, and that such incidental damage did not constitute the "taking" of property without just compensation or due process of law. Lastly, it asserted that the Thirteenth Amendment applies primarily to slavery and the removal of widespread disabilities associated with it; as such, the amendment undoubtedly would not place issues of racial discrimination in public accommodations beyond the reach of federal and state law.

The Lester Maddox concerning his Pickrick restaurant and his case to refuse to serve blacks.[3]

The U.S. Supreme Court held that Congress acted well within its jurisdiction of the Commerce Clause in passing the Civil Rights Act of 1964, thereby upholding the act's Title II in question. While it might have been possible for Congress to pursue other methods for abolishing racial discrimination, the way in which Congress did so, according to the Court, was perfectly valid. It found no merit in the arguments pursuant to the Thirteenth Amendment, finding it difficult to conceive that such an amendment might be applicable in restraining civil rights legislation. Having observed that 75% of the Heart of Atlanta Motel's clientele came from out-of-state, and that it was strategically located near Interstates 75 and 85 as well as two major Georgia highways, the Court found that the business clearly affected interstate commerce. Accordingly, it upheld the permanent injunction issued by the district court and required the Heart of Atlanta Motel to receive business from clientele of all races.

See also

References

^Text of Heart of Atlanta Motel v. United States, 379 U.S. 241 (1964) is available from: FindlawJustia

^ATLANTA MOTEL v. UNITED STATES, 379 U.S. 241 (1964), APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA. No. 515. Decided December 14, 1964., retrieved September 5, 2011

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